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Home My WebLink About95-04428 oj J . -7 ~ F ~ % -:T :::r '-... , .' -~:, .y I.II'?~ &d'. t'~/lrdJt~4 1J.~ l'II''l~ 7f~~ ,~:4/ ~~. .. ...- I . DEBORAH A. MEADE, Plaintiff : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 95-4428 CIVIL TERM VS. : CIVIL ACTION - LAW GREGORY L. MEADE Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO mE PRomONOTARY: Transmit the record, together with the following infonnation, to the Court for entry ofa divorce decree: I. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified Mail dated August 26, 1995 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the ~vorce Code: by Plaintiff: November 23, 1995 by Defendant: November 24, 1995 4. Relate claims pending: No related claims pending Respectfully submitted, ; ~JN--- Keith B. DeAnnond, Esquire Sup. Ct. 1.0. # 58878 DeAnnond &: DeAnnond 2800 Market Street Camp Hill, PA 17011 (717) 730-9394 Date: 12.(/$,(4/,$ , i - ~ /.r) .. C? 8$ J~ - .~ "- ~ Q.. G)~ 0 fE N 3@ I Ie:! :=!: ffirIi r- -r.~ EQCl.. '-) ~ lI. IJ) S 0 rn U . ". . r I I I t I I I I I f f I I f I , f I 1~~k~26~ .-- "0_. 'c OlllcJ.l Bu.In... PENALTY FOR PRIVATE use TO AI/OlO PAYMENT OF POSTAGE. S300 - US MAIL . 19~!>.' Print your nama, addrass and ZIP Coda hara · 'JjE.l}eAcneJ.. .~ f)(AR4ncnrl..-. _ t4~~~ ~4~ } ) . .. 111.'"...111"...."".11., ",.,.,...11,.,11.11...11",.",.1 .. ~ '-,' ..... .\ '. DEBORAH A. MEADE, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA ~ NO. 1(;' - 4- 4 ) g {J ( . r.t ~ ~ ,J lA-'l......~ VS. : CIVIL ACTION . LAW GREGORY L. MEADE. DEFENDANT : IN DIVORCE ORDER OF COllRT AND NOW. this~day of ~_, 1995 on consideration oflhe allached petition, it is hereby directed thai the parties and Iheir respective counsel appear before _M"<\.<u'\ L. g<V\?~. Esquire, the conciliator. at i o?- S. I ~r" 51--. G..""p II,JI on theattbday of ,",4..-(J~Ct'ffrr ,1995. at -H- .M. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis cannot be accomplished. to define and narrow the issues to be heard by the Court and to enter into a temporary order. All children age five or older may also be present at Ihe conference. Failure to appear at this conference may provide grounds for entry of a temporary or pennanent order. Hearing to be held at BY THE COURT, BY: .(VJ~"-'leP~. ~'n*",Si~1 Custody Conciliator ~/J j YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland Counly Courthouse Carlisle.I'A 17013 (717) 240.6200 )) . !. II. The Plaintiff avers that she has been advised of the availability of counseling and Ihat she may have the right to request that the Court require the parties to participate in counseling. Wherefore, the Plaintiff requests this Honorable Court to enter a Decree of Divorce in this matter pursuant 10 3301(c) or 3301(d) of the Divorce Code. COUNT II - CUSTODY 12. The averments of Paragraphs I through II are incorporated herein by reference. 13. Plaintiff seeks custody of the following child: Name Alex Gregory Meade Present Residence Age 901 A Bosler Avenue, Lemoyne, PA 4 years 14. In the past five years, the parties' child has resided with Ihe following persons, at the addresses and for the periods oftime indicated below: Plaintiff/Mother Plaintiff & Defendant 901 A Bosler Avenue, Lemoyne, PA 95 Decatur Drive, Grantville, PA 7/95 - Present 4/91 - 7/95 The child was not born out of wedlock. The child is presently in the custody of Deborah A. Meade who resides at 901 A Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. The Mother of the child is Deborah A. Meade who resides at 901 A Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. She is married. The Father of the child is Gregory L. Meade, currently residing at 95 Decatur Drive, Grantville, Dauphin County, Pennsylvania 17028. He is married. VERIFICATION I, Deborah A. Meade, the undersigned, do hereby verifY that the statements made in the foregoing instrument are true and correct to the best of my knowledge, information and belief. I understand that statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. (\0~n. ~ Deborah A. Meade Date: <b \.\ ~? DEBORAH A. MEADE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 95-4428 CIVIL TERM VS. : CIVIL ACTION - LAW GREGORY L. MEADE Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 18, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. .3. I consent to the entry ofa final Decree of Divorce. 4~ I understand that I may lose rights concerning alimony, division of property, lawyer's . fees or expenses if I do not claim them before a divorce is granted. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: / 1-1 ~-~ t; in~Lg~ '.'. ~ - ~:t - .. fi '" g: o~ :,:': Q<::! '" Sro - ~~ '-' Lu r- Q & IJ') a en . ~ M ~ .: z i~ M S~ - ;:: 'rf a:: ~~ 0 lD R= N ~I~ _._~ Co.) IBl F I,J C !:!..U- ~ ~ tn ::l en 0 '. 'ff"~"::,'.' -d~e! TOW >'l" r 111 ; '.... 'f ;~'.:'.. k ,,,'Jif~;:.:i .t ,. ~', :~; ',~ . .. , ~i;~:V ~.~~~~~,~. .- . ~ ~,.~t -i.:~~~~~ :}J'~:~~;'~~j?~:t:~:. 'c." ';<" @ DEBORAH A. MEADE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA : NO. 95-4428 CIVIL TERM VS. : CIVIL ACTION - LAW IN CUSTODY GREGORY L. MEADE Defendant M ~~T~RDER AND NOW, this~day of 1995, upon consideration of the attached Custody Agreement is is ordered and directed as follows: I. The Mother, Deborah A. Meade, and the Father, Gregory L. Meade, shall enjoy shared legal custody of the subjece minor child, Alex Gregory Meade, born April 9, 1991. 2. The Mother shall enjoy primary physical custody of the subject minor child. 3. The Father shall enjoy rights of partial custody as set forth below: a. During alternating weekends from Friday until Sunday. The specific time of custody shall be as the parties agree. b. Until said minor child is of sufficient age to attend school or kindergarten, Father shall enjoy weekly overnight visitation for two nights during the school week. After the subject minor child begins kindergarten or school, the midweek overnight visitation shall cease and Father shall enjoy whatever midweek partial custody that the parties agree upon. 4. The Mother and Father shall share physical custody on alternating holidays as the parties agree. .' " l':lQ 1. DEBORAH A. MEADE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-4428 CIVIL TERM VS. : CIVIL ACTION - LAW : IN CUSTODY GREGORY L. MEADE Defendant CUSTODY AGREEMENT AGREEMENT, made this~day of ~fpYn b" r 1995, between Deborah A. Meade, hereinafter referred to as Mother, and Gregory L. M e, hereinafter referred to as Father. WHEREAS, the above named Mother and Father had born to thern Alex Gregory Meade, on April 9, 1991. WHEREAS, the above named Mother and Father desire to enter into an Agreement as to the custody of the above said minor child and to the visitation rights of the non-custodian parent. NOW, THEREFORE, in order to effectuate the above purpose, the above named Mother and Father hereby agree that: I. The Mother and Father shall share legal custody of the subject minor child. 2. The Mother shall have primary physical custody of the subject minor child, subject to the Father's rights of partial custody as set forth below: a. During alternating weekends from Friday until Sunday. The specific time of custody shall be as the parties agree. b. Until said minor child is of sufficient age to attend school or kindergarten, Father shall enjoy weekly overnight visitation for two nights during the school week. After the subject minor child begins kindergarten or school, the midweek overnight visitation shall cease and Father shall enjoy whatever midweek partial custody that the parties agree upon. 3. The Mother and Father shall share physical custody on alternating holidays as the parties agree. 4. This Agreement may become an Order of Court. . 5. This Agreement may be modified or terminated in whole or in part upon written consent of both parties. If it becomes an Order of Court, rnodification of the Court Order is also required. 7. The parties hereto intend to be legally bound by the terms of this Agreement. IN WITNESS THEREOF, the parties hereunto set their hands and seals the day and year mentioned above. (h) tlJb,~-~"" CA-. ('('u,~ Deborah A. Meade, Defendant '('-'3-9, OCT 2 0 ZOOOtP vs. ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH A. MEADE Plaintiff NO. 95-4428 CIVIL TERM GREGORY L. MEADE Defendant CUSTODYNISIT A TION ORDER OF COURT ANDNOWthis /1-IJ..- dayof r?d , 2000, having not heard from the parties for some tirne, the undersigned Conciliator assumes the rnatter has been resolved and hereby relinquishes jurisdiction of the case. Ifeither oCthe parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, MICHAEL L. BANGS Custody Conciliator Mark T. Silliker, Esquire P. Richard Wagner, Esquire . ..... c:. f:; (1;; - "..: ...~ J..... -;';') , , ~ ;,J~ .. , - '\,.~ : ~ "",~~ ., ::J . . "5= , ..., i;~ N Va .- .- <.: "i)n.. c:: ;;,;: 0 ", ~..' l::;) 0 \